Anti-Bribery Anti-Corruption Risk
Abstract
Bribery and Corruption risk encompasses the likelihood of Endaoment or individuals associated with Endaoment engaging in unethical or illegal practices, including bribery and corruption in both onchain and offchain interactions. This risk involves the offering, giving, receiving, or soliciting anything of value to influence the actions of an official or other person in a position of trust. It also includes acts of embezzlement, fraud, and other corrupt practices that might occur either within Endaoment’s internal operations or through its external interactions.
Policy
Endaoment is committed to maintaining the highest standards of integrity and ethical conduct in all of its operations, adhering strictly to anti-bribery and anti-corruption laws and regulations. The policy aims to prevent, identify, and address any instances of bribery and corruption, ensuring transparency and fairness in all business dealings.
Scope and Applicability
This policy applies to all individuals working at or with Endaoment, including employees, contractors, board members, and any third parties acting on behalf of Endaoment. Adherence to this policy is mandatory, and any violations may result in disciplinary action, including termination or removal from the position.
Operational Controls + Testing
Endaoment will implement robust internal controls to monitor and mitigate bribery and corruption risks. These controls will be subject to regular testing and evaluation to assess their effectiveness and to ensure compliance with relevant laws and ethical standards. Any identified gaps or weaknesses in the controls will be promptly addressed.
Training
Comprehensive training on anti-bribery and anti-corruption practices will be provided to all Endaoment personnel. New employees will receive this training within the first 60 days of their employment. Ongoing training sessions will be held bi-annually to reinforce understanding and commitment to these principles.
Governance
The bribery and corruption policy will undergo a semi-annual review by the executive team to ensure it remains current and effective. All questions, concerns, or requests for exceptions to this policy must be escalated to and unanimously approved by the Endaoment executive team.